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Income Tax

Agricultural Income Claim Remanded for Lack of Proof

Case Law Details

TaxGuru Citation
2026 taxguru.in 470
Case Name
Deepak Vegpro (P) Ltd. Vs DCIT (ITAT Jaipur)
Date of Judgement/Order
Only available for paid members
Related Assessment Year
2022-23
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Deepak Vegpro (P) Ltd. Vs DCIT (ITAT Jaipur)

Agricultural Income Claim—Lack of Evidence; Matter Remanded to AO for Fresh Verification

In Deepak Vegpro (P) Ltd. v. DCIT, Central Circle, Alwar (ITA No. 1286/JPR/2025; AY 2022-23), the ITAT Jaipur Bench examined disallowance of ₹98,460 claimed as agricultural income.

The assessee claimed exemption on the ground that its land was leased for agricultural purposes to M/s Bhagwati Farms. The Assessing Officer disallowed the claim due to absence of supporting evidence, such as a lease agreement, crop records, or revenue documents. The CIT(A) confirmed the disallowance, noting that even though the assessee referred to documents like girdawari reports, no such records were actually produced.

Before the Tribunal, the assessee admitted that:

  • There was no written lease deed, only an alleged oral agreement, and
  • Relevant evidence proving actual agricultural use of land was not produced earlier.

Both parties agreed that the matter could be reconsidered afresh.

Decision & Directions:

  • ITAT held that the claim of agricultural income requires proper factual verification.
  • Matter remanded to the Assessing Officer for de novo adjudication.
  • AO directed to grant the assessee another opportunity to produce all relevant evidence (lease details, revenue records, proof of crops, etc.).

Outcome:

  • Appeal allowed for statistical purposes.
  • Issue of agricultural income restored to AO for fresh decision in accordance with law.

FULL TEXT OF THE ORDER OF ITAT JAIPUR

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Author Info

CA Vijayakumar Shetty
Qualification: CA in Practice
Company: Shetty & Co, Chartered Accountants, Mangalore
Location: Mangalore, Karnataka
Articles Published: 6,298

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